Yes.
See clause 7.6.3 of ISO22000.
"Critical limits shall be measureable.
.......'
Critical limits based on subjective data.................."
But I don't know why.
This cause is designed to leave us a chance to misunderstanding OPRP & CCP. right?
Hi Dux,
Clause 7.6.3 is simply addressing 'Critical limits" for
Critical Control Points.
As the next line in IS22K elaborates, it is just the limits to watch out for, for whatever 'Monitoring' we do at that
CCP.
Now, if the monitoring was of a 'variable' such as temperature, pressure etc, then we insure the accuracy of the monitoring by stuff like "Calibration of the equipment etc..." This would be the 'objective measurements.
But, if the monitoring was of an "attribute" such as " rinser water hitting base of bottle (to clean) " , then we would insure the "adequacy' of this attribute by training, the operator, providing visual comparison aids etc.
( Here I would like to acknowledge "Carlos Leoncini" for actually detailing the statistical tools that help us to deal with attributes in a scientific and logical manner.)
In short, the
CCP monitoring has to be able, to be compared to logically derived "upper and / or lower limits" which ensure the
CCP is in control. There is no restriction on whether the parameter being monitored has to be an "numerical variable" or " subjective attribute".
Within this clause, the OPRPs are not referred/relevant.
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With OPRP, as with other PRP they are a "Pre requisite" and hence our
HACCP is built on the premise that these are in place and implemented to a level where their effectiveness is adequate to control the hazards they address.
As with other PRP they would have their own 'monitoring' to ensure this. --- 7.5.C (in IS22K)
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Many thanks for raising such an interesting topic..
Cheers,
Sriram